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On Notice: “Notice at Collection” and Privacy Policy Requirements Under the CPPA’s Draft Regulations

Among the many details to absorb in the draft amendments to the CCPA regulations published by the California Privacy Protection Agency (“CPPA”) on May 27 (the “Draft Regulations”) are new and prescriptive disclosure...more

New California Draft Privacy Regulations: How They Would Change Business Obligations and Enforcement Risk

On Friday May 27, 2022, the California Privacy Protection Agency (CPPA) Board announced its next public meeting will be on June 8, 2022. The announcement simply stated the date of the meeting, that there are “some discussion...more

How the Utah Consumer Privacy Act Stacks Up Against Other State Privacy Laws

As companies wait to see whether the Utah Consumer Privacy Act (UCPA) becomes the fourth comprehensive state privacy law, we are providing an overview of some of the Act’s key provisions – and how they depart from...more

California AG’s First CCPA Opinion Takes a Broad View of the Right to Access Inferences

In the first formal written opinion interpreting CCPA compliance obligations, California Attorney General Rob Bonta concludes that the CCPA grants consumers the right to know and access internally generated inferences that...more

[Webinar] Privacy Priorities for 2022: Tracking State Law Developments - March 24th, 4:00 pm - 5:00 pm ET

In the absence of a federal privacy law, privacy has been at the forefront of many states’ legislative sessions this year: - Utah is poised to be the fourth state to enact comprehensive privacy legislation - Florida...more

Soltani Appointed as Inaugural California Privacy Protection Agency Executive Director

During last month’s California Privacy Protection Agency Board (CPPA) meeting, the only substantive agenda item, addressed in closed session, was a discussion of two key appointments: the first Executive Director and a Chief...more

CPRA Update: California Privacy Rulemaking Process Begins

On September 22, the California Privacy Protection Agency (CPPA) issued an invitation for public comments as part of its first “preliminary” rulemaking activities. Established by the California Privacy Rights Act (CPRA)...more

Privacy Law Update: Colorado Privacy Bill Becomes Law: How Does it Stack Up Against California and Virginia?

The Colorado Legislature recently passed the Colorado Privacy Act (“ColoPA”), joining Virginia and California as states with comprehensive privacy legislation. Colorado Governor Jared Polis signed the bill (SB 21-190) into...more

Colorado Passes Privacy Bill: How Does it Stack Up Against California and Virginia?

The Colorado Legislature recently passed the Colorado Privacy Act (“ColoPA”), joining Virginia and California as states with comprehensive privacy legislation. Assuming Colorado Governor Jared Polis signs the bill (SB 21-190)...more

CPRA Update: CalPPA Gets Started with Inaugural Meeting and Agenda

Just a few months after California officials announced the nominations of the inaugural Board members of the California Privacy Protection Agency (“CalPPA”), the CalPPA released the agenda for its first board meeting on June...more

California Privacy Protection Agency Appointments Announced

California officials today announced their nominees to be the five inaugural members of the California Privacy Protection Agency (“CPPA”) Board. Created by the California Privacy Rights Act (“CPRA”), the CPPA will become a...more

Further Amendments to CCPA Regulations Are Approved and in Effect

California’s Office of Administrative Law approved further revisions to the Attorney General’s CCPA regulations on March 15, 2021. The revisions went into effect upon approval. In substance, the revisions are identical to...more

Two’s Company: Virginia Has a Comprehensive Data Privacy Law

On March 2, Governor Ralph Northam signed the Virginia Consumer Data Protection Act (VCDPA) into law, making Virginia the second state to enact comprehensive privacy legislation. With the VCDPA on the books, companies have...more

Zoom Agrees to Settle FTC’s Data Security Charges

Seven months after being called upon by members of Congress to investigate Zoom’s data security practices, a divided FTC announced on November 9 a settlement with the videoconferencing platform....more

It’s Here: California Voters Approve the CPRA

On Tuesday, November 3, 2020, California voters passed ballot Proposition 24, the California Privacy Rights Act of 2020 (“CPRA”). Also known as CCPA 2.0, CPRA brings a number of changes to the CCPA, the majority of which will...more

California Privacy Legislation Round-Up: Gov. Newsom Signs CCPA Employee Exemption Extension, Vetoes Others

Prior to the September 30 deadline to sign or veto legislation, California Governor Gavin Newsom recently took action on three bills related to data privacy. Bringing some potential certainty to the dynamic CCPA landscape,...more

CCPA Update: Final Regulations Submitted but No Changes from Prior Draft

On June 2, California Attorney General Xavier Becerra announced that he had submitted final CCPA regulations to the Office of Administrative Law (OAL) for review. The final regulations are substantively identical to the...more

The CCPA Non-Discrimination Right, Explained

The California Consumer Privacy Act (CCPA) provides consumers with a right to non-discrimination when they exercise other privacy rights guaranteed by the law, such as the right to access, delete, or opt out of the sale of...more

Data Privacy Considerations for Coronavirus Data Tools

Data is helping governments, researchers, and companies across the world track the spread of the novel coronavirus, monitor cases and outcomes of COVID-19, and devise ways to halt the virus’s spread. As part of these...more

Facial Recognition Tech Enforced by Vermont AG Under State Privacy & Data Broker Laws

Vermont Attorney General Thomas Donovan Jr. has ratcheted up ongoing scrutiny of facial recognition technology. On March 10, the Vermont AG sued facial recognition technology provider Clearview AI and moved for a preliminary...more

CCPA Update: Attorney General Releases Third Draft of Proposed CCPA Regulations

On Wednesday, the California Attorney General (AG) released a third draft of proposed CCPA regulations for public comment. The draft contains a series of technical corrections, along with a handful of substantive incremental...more

Manufacturing “Smart” Devices? NIST Security Has Recommendations

Regulatory interest in Internet of Things (“IoT”) devices is growing, partly in response to concerns about device security. In January, for example, California’s IoT Law (SB 327) went into effect. This law requires...more

CCPA Update: Attorney General Proposes Modified Draft Regulations

On Friday, California Attorney General Xavier Becerra released proposed modifications to the formerly-released draft regulations implementing the California Consumer Privacy Act (CCPA). The modifications reflect the Attorney...more

The U.S. Approach to Privacy: What Is It, and Where Is It Headed?

As we mark Data Privacy Day, today is a good time to take stock of where U.S. privacy legislation stands in relation to the developments of the past few years. In less than two years, the GDPR and the CCPA became the most...more

CCPA Implementation: An Early Map

The January 1, 2020 effective date of the California Consumer Privacy Act (CCPA) has come and gone, but questions about how to comply with the law show no hint of disappearing. As companies move past their efforts to comply...more

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